Dr. Caroline Snyder reminds us that "The Dirty Work of Promoting "Recycling" of America's Sewage Sludge"began in the late 1970s when the first land application regulations were formulated by political appointed "managers and scientists in EPA’s Office of Water (OW): Henry Longest II, John Walker, and Alan Hais." "Despite the fact that sewage sludge is a contaminated waste product, it is being commonly treated and used as a fertilizer, without informing the recipients about the complete contents of the sludge." EPA and it's wastewater industry partners have attempted to "control the flow of scientific information, manipulate public opinion, and cover up problems, ignored or concealed reported health problems, threatened opponents with litigation, distributed misleading information to the media, legislators, and the public, and above all, attempted to silence critics."

Lying to the public through the media has become a national pastime for the wastewater industry since the Powell Tate Public Relations firm laid out the strategy in 1993 to convince the public that toxic sludge is good for you.An example is the April 30, 2008 story in the Baltimore Examiner by Karl B. Hille , "Reports confusing Orgro Class A compost with sewage sludge irk compost makers. Treated compost not same as sludge, maker stresses." According toJohn Myers, "a consultant for the Curtis Bay Orgro Composting Facility", "The EPA routinely tests both the incoming sludge and the final product for harmful bacteria and heavy metals." He said, "Compost is a safe, biologically rich topsoil spread in gardens, lawns and landscaping."

Routine testing at maximum capacity of 210 ton a day would be once a month.

Facilities that produce up to 290 metric tons annually must monitor once each year;

Facilities which produce 290 to 1500 metric tons annually must monitor once each quarter (four times per year);

Facilities producing 1500 to 15 000 metric tons must monitor once every 60 days (six times per year); and

Facilities producing 15 000 or more metric tons must monitor monthly (12 times per year).

If the compost was not classified as a sludge product, it would have to be disposed of as a solid waste. Furthermore, the EPA does not test Orgro Class A sludge compost for harmful bacteria. Nor does EPA require that the Orgro facility operators test for harmful bacteria. EPA admits harmful pathogens will be in the final compost product. EPA only requires that a combined multi-sample (7) of sludge be tested for a high temperature mutant indicator coliform which EPA says is not harmful. Not only that, but Orgro is only required to test for 9 toxic heavy metal (pollutants) out of the CERCLA (superfund) Priority List of 275 Hazardous Substances determined to pose the most significant potential threat to human health due to their known or suspected toxicity and potential for human exposure at superfund sites.

The nine pollutants the compost facility are required to test for are also priority toxic pollutants. According to EPA, "The term "toxic pollutant" is not used in the final part 503 regulation because this generally is limited to the list of priority toxic pollutants developed by EPA. The Agency concluded that Congress intended that EPA develop the part 503 pollutant limits for a broader range of substances that might interfere with the use and disposal of sewage sludge, not just the 126 priority pollutants."

Therefore, the compost facility operators, Baltimore and elsewhere, have no idea what level of hazardous toxic pollutant substances are in the final sludge product. According to the original 1988 compost studies for distributed and marketed compost, "Composts modified with various materials to produce commercial soil amendments contained significantly higher concentrations of bacteria and fungi than the base compost material. The data suggested a nutrient-related regrowth phenomenon." Not only that, but "Efforts to characterize major unknown organic components were limited to computer comparisons of GC/MS peaks to the NBS mass spectral library. In none of the cases was a tentative identification made. " "As a result, a significant portion of the major peaks were multi-component peaks whose identities remain completely unknown."

No one knows what is in this sludge product, but the public has become the victim of this outrageous conduct."The ultimate insult to Congress and the American public was given in a letter to Congressman Conduit, dated October 1, 1993, by Martha G. Prothro, (EPA) Acting Assistant Administrator. She states that, "If the placement of sludge on land were considered to be "the normal application of fertilizer"--it--"would not give rise to CERCLA [superfund] liability for the municipality generating the sewage sludge, the land applier, the land user or the land owner." This was also stated in the preamble to Part 503.

So, what happens when a sludge site is sold to a developer? In Riverside, California, "Based on the alleged contaminated soil, residents from three homes in the more than 200-home tract who filed the lawsuit say they and their families have suffered health problems including weight loss, hair loss, fevers, sinus problems, nose bleeds, fatigue and a host of other ailments." What could cause the problem? Hazardous "Endotoxins, which are released when bacteria is destroyed, have been known to cause severe inflammation in any tissue exposed to them, including lung tissue, according to the national Centers for Disease Control and Prevention."

It would appear EPA's sludge rule relieves everyone of federal liability for creating a hazardous waste open dump site on agricultural land, even if becomes your lawn. However, that doesn't prevent the present or future land owner from having to deal with lawsuits over the contaminated land. Now, EPA denies any responsibility, "EPA's role in the management of industrial nonhazardous Waste [sludge] is very limited. Under RCRA Subtitle D, EPA issued minimal criteria prohibiting "open dumps" (40 CFR 257) in 1979. The states, not EPA, are responsible for implementing the "open dumping criteria," and EPA has no back-up enforcement role."

EPA and WEF have recklessly promoted sludge as a safe fertilizer. Yet, the documents tell a much different story.In 1993, EPA claimed it did a 14 pathway risk assessment for sludge used as a fertilizer on agricultural land under Part 503. At the same time it claimed to have a lack of data on most chemicals in sludge. Part 503 was Peer Reviewed by old time sludge researchers and regulators, including EPA's James Ryan and USDA's Rufus Chaney. In a 1992 EPA memo we discover that Ryan and Chaney also rewrote the part 503: "The sludge rule discussions with OW are on hold waiting for Ryan and Chancy' s rewrite." The question was: "Are human health and the environment "pretty safe" with the application rates drafted, or does the Administrator need to hear that major work is necessary just to be pretty safe? Can we feel ok as long as the uncertainty is fully discussed, both in the preamble and the guidance documents?" "Options facing the Agency if the problems persist in the next edition include boldly publishing on admittedly weak science, using a factor of safety to compensate for any weakness, or scrapping the whole exercise, promulgating the Feb 89 proposal as interim." In the guidance documents in 1995, EPA admitted it did not use any of the 13 chemical risk assessments on file and did not consider any of the toxic heavy metals to be carcinogens -- contrary to EPA's own 1989 list of carcinogens in the proposed 503 -- which was not included in the final part 503.

"In a 1995 paper, James Ryan of the EPA and Rufus Chaney of the USDA, describe how even flawed risk assessments are used in making risk management decisions. According to them: In this risk assessment process it is soon apparent that lack of data, inappropriate data or inadequate data on the dose-response relationship, environmental exposure or population risk make implementation of the risk assessment difficult and lead to generalization and or acceptance of inadequate data. However, even with these flaws, if done in an objective manner the risk assessment serves as a useful analysis for risk management. "

Of course, any sludge researcher or judge, who did not read the paper, or the preamble to Part 503, might assume EPA actually did a legitimate risk assessment. EPA/WEF pro-sludge research is done by third parties with strict guidelines. Generally, a pro-sludge researcher can make positive statements based on limited research and data without their integrity being questioned because of the limitations noted in the study. However, when EPA agents with an agenda funds a sludge study such as the one focusing on the Georgia cattle deaths, scientific researchers should beware! Julia Gaskin of the University of Georgia is learning this lesson the hard way, in court charged with fabricating data to cover up cattle deaths on a Georgia farm. "She also says that the paper was never intended to study problems with biosolids on the dairy farms. “The purpose of this paper was not the focus that has been alleged,” she says. “That was not part of this effort." It will be interesting to see how that defense holds up in court.

EPA warned the public and researchers, "When sewage sludge is not used to condition the soil or to fertilize crops or vegetation grown on the land, the sewage sludge is not being land applied. It is been disposed of on the land. In that case, the requirements in the subpart on surface disposal in the final part 503 must be met."

You have to read that sentence twice. Yes, it really does say if you are not fertilizing some type of plant life, the sludge/biosolids must be disposed of in a permitted part 503.23 surface disposal monofill (landfill). In many cases the sludge/biosolids will be too contaminated to do so.

Moreover, "EPA concluded that adequate protection of public health and the environment did not require the adoption of standards designed to protect human health or the environment under exposure conditions that are unlikely and where effects were not significant or widespread."

The Baltimore lead study in the black neighborhood is a good example of unlikely exposure conditions. With only nine yards involved and a few children involve, the effects were not significant or widespread. The same is true for the black neighbors around sludge sites in Virginia, Carolinas' and Georgia. It isn't really a racism thing -- these waste industry people (EPA/WEF) have no respect for human health and life regardless of race. It is unfortunate that Dr. Gary W. Goldstein, president and chief executive officer of the Kennedy Krieger Institute and Dr. Michael J. Klag is dean of the Johns Hopkins University Bloomberg School of Public Health happen to get caught in the middle of the EPA/USDA/WEF public relations ploy.

The EPA statement that adequate protection of public health wasn't required for the sludge rule is in direct conflict with the mission statement: "The mission of the Environmental Protection Agency is to protect human health and the environment." "Since 1970, EPA has been working for a cleaner, healthier environment for the American people."

However, the operating legal theory behind the sludge rule has been that the laws and regulations are there to protect the general public (i.e. American people) , not individual people. As an example, if a farmer is too damn dumb to question why it is safe for him and his family to be exposed to sludge/biosolds, but the public can not be expose to it, then he deserves to suffer the ill effects and possible death of his loved ones as EPA outlines in Part 503.9(t). Not to mention possible lawsuits from the damage he does to his neighbors health and environment. This is a case where having close neighbors is unlikely, and if he did, they would be so few the effects would not be significant or widespread.

Medical general practitioners (family doctors) have no idea how to deal with sludge victims exposed to so many pollutants. As my doctor says, "its impossible, the government would not allow that to happen." So doctors treat the symptoms and if they don't understand the autoimmune system symptoms, the patient has to be imagining the health problem, that only an endocrinologist could understand. As Andrew F. Stewart MD, Chief, Division of Endocrinology,University of Pittsburgh School of Medicine noted there are serious problem ahead. In 2006, according to the American Board of Internal Medicine (ABIM),there were "approximately 4,000 M.D. endocrinologists available in the US whose primary focus is to provide clinical care." "The endocrinologist shortage has impaired access to care by patients with diabetes, obesity, metabolic syndrome, lipid disorders, thyroid nodules, thyroid cancer, osteoporosis, pituitary disease, adrenal disease, menopausal symptoms, and reproductive disorders. It is standard to encounter waits of 3 to 9 months, and many endocrinology practices are closed to new patients."

The rural victim of sludge exposure is literally up the creek without a paddle. Of course, the city dweller exposed to hormone disrupting chemicals released in sewage effluent and passed through the drinking water treatment plants are in the same boat. This is just a prelude to an admitted pandemic when doctors will have to decide who to let die.

Two sides to this coin

Since the EPA/WEF position is that all sludge/biosolids use and drinking water is safe and the victims are required to prove its not, "STATE AND FEDERAL HEALTH OFFICIALS SAY "NO DOCUMENTED CASES OF ILLNESS (FROM SLUDGE)" ... YOUR SYMPTOMS ARE "PSYCHOSOMATIC."

Jodi L. Sokolowski, reporter for the VIRGINIA newspaper - THE WINCHESTER STAR - SEPT. 28, 2002 gave us two examples of this mentality. 1). " Synagro's public affairs manager, George Clarke, said thecause for concern is mostly psychological. "If it smells bad, it must not be good for me," he said rhetorically." and 2). Cal Sawyer, of the Virginia Department of Health's Division of Wastewater Engineering, said these medical mysteries are worrisome. "If these people are alleging that biosolids are causing all these problems, some of these people might have health problems that aren't being looked into," he said. Blaming biosolids "is not doing them a favor. They're not looking at what really might be the problem." He added that the department did not start to receive complaints about biosolids until Internet use became more common. "It's mass hysteria. If you suggest they will get ill, they will get ill," he said." What the Internet did was expose the industry lies to public scrutiny. That is a good thing.

As pointed out in the document, PRECAUTIONARY ACTION SHOULD BE MANDATORY, "Since EPA began exposing the public to sludge and reclaimed water use, the industry claims there have been no health problems within the wastewater industry. Therefore the public can not possible experience any health problems from exposure to sludge and reclaimed water. That is a serious indicator that we can not trust the words of the wastewater treatment industry. In fact, Hadeed, National Biosolids Partnership (NBP) Technical Communications Director it appears, likes to have a little fun at the expense of country folks, He said "Odors, quite frankly, are the number one reason for lack of public acceptance of biosolids." Then he gives us a little rhyme, "Odors, odors everywhere and all the biosolids did stink, Odors, odors everywhere but Not In My Back Yard you fink! - Rhyme of the Ancient Biosolids Manager (S.J. Hadeed, 2000)"

The fact is these folks making fun of us have to know the chemicals causing odors can be killers. Yet, It would - appear Mr. Hadeed never completely read the EPA document on Amines in ODOR CHARACTERIZATION, ASSESSMENT AND SAMPLING from sludge. Based on the above opinion, it is probable that Mr. Haeed stopped reading when EPA mentioned somatic impacts of odors. Somatic means "of the body", or Somatic Cells from the body that compose the tissues, organs, and parts of that individual other than the germ (sex) cells.

Psychosomatic (neurotic) appears to be the way the term somatic was interpreted. Like Hadeed, "William Toffey, who oversees Philadelphia's waste program, swears biosolids is safe. He is, in fact, a little giddy about composted human waste. "Biosolids are fun," he said." Toffey even wrote a paper, Biosolids Odorant Emissions as a Cause of Somatic Disease . However, Toffey admits, "noxious odors, have occurred, even with some regularity. Examples of such cases are putrid biosolids compost along highways, noxious advanced-alkaline stabilized biosolids near elementary schools, and stinky piles of biosolids pellets in a farmer’s field." But then he said, " Experts to the wastewater profession have not been able to dismiss the role of biosolids in triggering IEI and psychogenic illnesses." "The psychogenic theory presupposes that idiopathic environmental intolerance (IEI) is an overvalued idea explained by psychological and psychosocial processes." I do believe he just said us old country folks are crazy and the industry bought experts will not consider otherwise?"

Of course, us crazy folks are not supposed to know that these EPA/WEF members don't do their job very well. According to government documents, "A recent EPA report [2004] by the Office of Enforcement and Compliance Assistance documented extensive non-compliance with the CWA. In 2002, 83 percent of facilities in SNC [significant non-compliance] were repeat SNCs. In 2001, 25 percent of major facilities were in SNC. Sixteen percent-29 percent remained in that status for 2 years or longer. Of those that returned to compliance, there is a 50/50 probability that they will return to SNC again within 2 years."

As Dr. Edo McGowan noted in a 2007 editorial, "A 2004 WERF paper that studied sewer plants from coast to coast noted problems not only with reclaimed water but with the standards as well. The WERF study noted that plants in their production of recycled water actually met standards somewhere between 33% and 66% of the time. Giardia cysts were found in 84% of the final recycled/reclaimed water samples. Enteric viruses were detected in 31% of the final effluents of two-thirds of the studied facilities and Cryptosporidium oocysts in 71% of the final recycled/reclaimed effluents. Viable Cryptosporidium oocysts were detected in 30% of the final recycled/reclaimed effluents in two-thirds of the tested facilities". The study concluded that the standards did not protect public health." The authors of the WERF paper, Joan B. Rose, et.al. made a strange claim, "Reclaimed water as monitored in this study in Arizona, California and Florida is not pathogen free, and exposure of the public to these waters carries some risk, albeit this level may be very low and quite acceptable to most populations." Does that mean the use of reclaimed water with low pathogen levels used on lettuce and spinach grown in the Salinas Valley, California outbreakwas acceptable to the population that got food poisoning, the dead population or to the population that didn't get food poisoning -- or just to most populations operating and regulating the treatment systems, and the promoters of reclaimed water? As retired government soil scientist Frank Pecarich says, "I have to accuse these people of a cover-up, pure and simple. They have been dissembling information for years it appears. It is time to put an end to this collusion and subterfuge. Our food safety, our lives and our children's lives are at stake."

The sludge promoters like to bring religion into the mix. In BSE, The Bible and Biosolids: Fighting Fear with Fun, Frankness and Familiarity, we find that If William Toffey, manager of Philadelphia's biosolids program, can not convince us we are crazy -- then its best to make fun of us -- because the industry is operating on instincts rather than science. Toffey said, "Can it be possibly true that biosolids are part of a process for making humans, as well as the soil, healthy! The concern we hear in the community about exposure risks may prove, in the end, to have an ironic twist – it may be a health benefit. Certainly, we need to explore the scientific aspect of the issue, and not cede ground on this one either."

Toffey says sludge exposure is good for you, "One of the citations in the litany of “scientific” documents took me to some exciting health literature about which we need to be more aware, science that proves the Hygiene Hypothesis, previously known as the Clean Kid Syndrome. This hypothesis says that unless we are challenged as young people to dirt and manure, our bodies do not develop an immune response that protects us from allergens and toxins; allergies, asthma and cancers can occur in higher than expected incidence rates if kids are too clean!" I believe the theory is:"if it does kill you, it makes you stronger."

Toffey admits the product may have problems, "Achieving a good quality biosolids product has been an afterthought in many treatment plant designs. In the future, a commitment to a good looking and pleasant smelling biosolids will need to be foremost. We need to communicate this new commitment to our utility customers."

Toffey also admits the industry has no idea of the sludge exposure risks, "The biosolids industry is facing many new questions -- emerging pathogens, persistent organic pollutants, radioactivity, and endocrine disrupter's. No matter how keenly our instincts tell us that these issues pose very little risk, we have no conclusive data on the risks they pose."

Dr. McGowan has researched this issue. He said. "Keep in mind that the industry does not require knowledge in these areas, so, how would they know if they did or did not have problems, they don’t even understand the question. DHS is the states dept of health services and has recently changes its name to dept of public health, but still they don't know any more. The number 2 man in their drinking water division, same division that handles recycled water told me that if I wanted the agency to look at antibiotic resistance, to go out and get a politician to make new law that would force them to look at this, otherwise they were unable to do anything. In reality, they are moribund by lack of funds and interest because of other priorities, and they don't seem to really understand the issue which is odd for an agency compelled by law to look out for the public health. Perhaps that is the key ---- compelled by law and not necessarily common sense."

What people really don't understand is why Toffey and the industry works so hard to get this pollution so close to humans and have no concern for polluting the air, water and food supply when they have known about the pathogen reactivation/regrowth phenomenon in sludge during sludge treatment since 2001." Of course, they have known about antibiotic resistant and viable, but nonculturable bacteria for 30 years.

I do believe Dr. McGowan was right about the industry's level of knowledge. There is no such thing as Fecal Coliforms. Fecal coliform are the mutant coliform that grow at 44.5° C. (112.1° F). A coliform includes all of the gram negative bacteria that are defined by their ability to ferment lactose within 24 - 48 hours incubation at human body temperature of 35-37° C (95-99°F). EPA falsely claims that none of the bacteria included in the coliform bacterial group cause diseases in humans.

E. coli and Salmonella are two of the coliform bacterial group as well as the fecal coliform bacterial group. The document really does not tell us much when it states, "In summary, the body of knowledge to date from a limited number of plants seems to indicate that some plants with a combination of anaerobic digestion and centrifuge dewatering may be experiencing fecal coliform reactivation and/or regrowth. For utilities that use BFPs for dewatering of anaerobically digested biosolids, fecal coliform reactivation/regrowth was not observed in the small number of plants reviewed. However, it is important to note that the literature to date suggests that anaerobic digestion processes—whether mesophilic, thermophilic, or TPAD—rather than destroying fecal coliforms, may convert them to a viable but nonculturable state, whereby they can be reactivated by centrifuge dewatering but not BFP dewatering. Because the mechanism for reactivation is unclear, it is conceivable that the viable but nonculturable fecal coliforms in the BFP biosolids could also subsequently be reactivated at some point. Thus, low counts in the BFP cake versus elevated counts in the centrifuged cake may not be relevant. Because fecal coliforms are indicator organisms, the “reduction” of which during digestion is assumed to coincide with a reduction to acceptable levels of pathogens, it raises the question as to whether there is really an issue or simply an analytical artifact. Thus, evaluating the direct relationship between fecal coliform regrowth/reactivation and actual pathogenic activity in biosolids is needed."

Has the WEF really changed since it started it "sludge horror story" debunking program in 1995? Now WEF says,"Agencies may also want to share the information from the WERF regrowth/reactivation study with their citizen constituents and other interested parties. It may take considerable effort (presentation and discussion) to sharethis information and what utilities and the wastewater profession are doing as a result. However, this will be worthwhile as it will inform people as to the complex issues that environmental professionals and their served communities sometimes have to address."

It is clear, WEF members can no longer hide the science showing sludge use is unsafe including such information as the study by Dr. Julia Ljubimova which found "Hundreds of studies have linked air pollution to early deaths, heart attacks, reduced lung function, lung cancer and various other health problems. Ljubimova is among a handful of scientists who are focused on finding out what air pollution does to people's brains." Yes, "Research suggests breathing in pollution could trigger brain cancer"

Another study found," Harmless protozoa that live on grocery store greens can shelter deadly food pathogens like E. coli and Salmonella. A laboratory study has found that food pathogens survive being eaten by protozoa living on spinach and lettuce. The temporary asylum might help bacteria stick onto leafy greens or resist efforts to kill them before packaging."

EPA/WEF have been claiming a 1984 Ohio sludge study that was never competed to prove sludge use was safe. However, a new found just the opposite. The authors state, "We observed an association between respiratory, gastrointestinal, and general symptoms linked with infectious diseases and residence in homes near farm fields permitted to receive Class B biosolids. Moreover, we found a significant dose-response relationship for excessive secretion of tears, abdominal bloating, and dehydration. These findings are in agreement with the findings of Lewis et al9 and studieson wastewater treatment workers.7 However, they contradict an earlier study from 3 areas in Ohio, in which researchers reported no significant differences in the risk of respiratory, gastrointestinal, and general symptoms between sludge-farm residents and control-farm residents. In the Ohio study, the biosolids application rates were low and thus exposure levels may not have been comparable to those inthis study."

"In conclusion, our findings suggest an increased risk for certain respiratory, gastrointestinal, and other diseases among residents living near farm fields where the application of biosolids was permitted. Moreover, the reported occurrence of certain chronic diseases, such as multiple sclerosis, were elevated in the exposed group. Further studies are needed to determine the relation between time fromlast application of biosolids and reported health effects as well as to address cited limitations."

But the PR program goes on in an effort to control the media and public response.